The United States Supreme Court has held that an assault and battery committed by an off-duty government employee is not barred by the intentional tort exception of the Federal Tort Claims Act where other government employees are negligent in failing to prevent the assault and battery.
Sheridan v. United States, 108 S. Ct. 2449 (1988).
Government Liability - Federal Tort Claims Act - Intentional Tort Exception,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol27/iss4/11